I have been advised by the Central Bank that where proof of identity is required, the industry standard is to adopt a “One plus One” approach meaning that one item should be sought from a list of official photographic identification documents such as a passport to verify the name and date of birth of a prospective customer, while a second item should be sought from a list of non-photographic identification documents in order to verify the prospective customer’s address. Depending on the Credit Union’s own risk assessment of the customer, additional ID verification may be required. The relevant statutory provision is set out in section 33(2)(a) of the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 – 2013. While it is up to each institution to decide on a risk based approach whether they will accept other forms of customer ID, the documentation set out above should be considered the standard expected to be applied in most cases to meet the obligation in section 33 of the Acts to confirm the identity of the customer.
However, guidelines which were devised by the Irish League of Credit Unions in January 2013 provide assistance to credit unions with younger prospective customers. These guidelines state that in exceptional circumstances and only in cases where the standard approach to customer identification and verification could not reasonably be expected, consideration may be given to (inter alia) address verification in writing, signed and on headed paper from a reputable third party. A third party could be an employer, school, college, money advisor, solicitor, priest, care-home or shelter manager, probation officer, government office or local authority official.